Investors should note that investment decisions relating to the funds to which SMT Fund Services (Ireland) Limited (the “Management Company”) acts as UCITS management company/AIFM (as appropriate) are taken by the underlying investment managers and as a result, the Management Company does not consider sustainability risks in the investment decision making process for the funds.

The Management Company does not currently consider the principal adverse impacts of such investment decisions on Sustainability Factors, which are defined in Article 2 of the EU Sustainable Finance Disclosure Regulation (SFDR) as “environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters”.

The Management Company has opted against doing so, primarily as the regulatory technical standards supplementing SFDR which will set out the content, methodology and information required in the principal adverse sustainability impact statement remain in draft form and have been delayed. The Management Company intends to consider the principal adverse impacts of investment decisions on Sustainability Factors once the regulatory technical standards come into effect, which is expected to occur on 1 January 2022.